leads me to post this straight from The CPSC FAQ page:
Q: Do all children's products require testing for lead or is it only products with
some type of surface coating? We sell products that are used in physical education
classes (e.g. hula-hoops) that are made from polyethylene and are not painted or
coated. Will this product require third-party testing and certification for lead
content under the new CPSIA?
A: All children’s products (as defined by the CPSIA) subject to the lead limit of the Act
will eventually require testing for lead, not just those with surface coatings. It is
important to distinguish between the rules that apply to lead paint and surface coatings
and the rules that apply to lead content. The CPSIA provides limits to the amount of lead
in paint and surface coatings and limits to the amount of lead in the content of the product
itself. Children’s products that are painted, or have surface coatings are also subject to
the lead paint limit, in addition to the lead content limits.
The reason I reprinted this here is because there is still confusion among small manufacturers on etsy and the like that make products primarily intended for children under the age of 12 that think this law doesn't apply to them. Clearly, from the above stated, IT DOES! There is no loophole, there is no exemption (right now), and there is no magic bullet. So far, the CPSC is taking comments regarding component testing, and also ruling on whether certain materials such as uncoated wood and natural fibers (undyed) should be exempt. They have not yet ruled on these questions. I think we should all devote ourselves to changing this law, not arguing amongst ourselves whether it applies or not. IT DOES. Enough said.
Tuesday, December 30, 2008
Monday, December 29, 2008
CPSIA Comments, Question 5
"Whether and how the use and control of subcontractors would be affected by
allowing the third-party testing of component parts."
This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement. So here goes.
A quality control system would have to be put in place that may include randomizing testing and implementing stricter quality control processes. Instead of checking the first few from a production run, a manufacturer might pull and spot check somewhere down the production line. That way if the contractor has substituted a tested component for another, a check against the original components could be performed. In the apparel industry, this could be performed by a visual inspection compared against the original compliant components specified by the manufacturer.
As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, might be difficult to tell without doing random unit testing. However, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer versus component testing. It really comes down to random quality control.
I welcome all of your comments to help me formulate these responses, as I'm pretty sure I'm not aware of many of the complicating factors that many businesses face.
_________________
allowing the third-party testing of component parts."
This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement. So here goes.
A quality control system would have to be put in place that may include randomizing testing and implementing stricter quality control processes. Instead of checking the first few from a production run, a manufacturer might pull and spot check somewhere down the production line. That way if the contractor has substituted a tested component for another, a check against the original components could be performed. In the apparel industry, this could be performed by a visual inspection compared against the original compliant components specified by the manufacturer.
As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, might be difficult to tell without doing random unit testing. However, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer versus component testing. It really comes down to random quality control.
I welcome all of your comments to help me formulate these responses, as I'm pretty sure I'm not aware of many of the complicating factors that many businesses face.
_________________
Sunday, December 28, 2008
Inspired by a Pillow
To take a break from my CPSIA crusade, I wanted to write a little bit about how I am inspired. It really comes in all forms. Sometimes I'll see a shirt detail, something in nature, a colorful room, and each one of those things will get me thinking.
This time I was thumbing through Metropolitan Home on the airplane headed from Boston to Detroit. I spied that wonderful pillow you see pictured with the black and white polka dots. I love the strips of fabric and how the fabric was folded in on itself. Well, the rest just followed. Thinking on my stash at home I decided that Amy Butler's martini polka dot would be the perfect fabric on which to try this out. So, down to the workroom I went. I really wanted to leave the tucks un-sewn, but when that didn't work, I put plan B into action and topstitched each of the slanted pleats, and the result is what you see.
The gathered skirt has three horizontal growth pleats (mainly because I needed to shorten the length), but the real design feature is several criss-crossing pintucks that flirt around the bottom of the skirt. I like the way these mimic the slanted pleating on the yoke. Whoever said you needed to sew straight lines!
I love getting inspiration from other designers, but obviously my dress is nothing like the pillow, just my own take on it. I don't think any designer designs in a vacuum. There are always those who come before, and after all the human form hasn't changed much over the centuries. Thanks to Amy Butler, as her fabric lends itself perfectly to this style, and I can't wait to try it in different colors.
Saturday, December 27, 2008
CPSIA Comments, Question 4
On to Question 4:
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
Friday, December 26, 2008
CPSIA Question 3
Forgive me if this is a tad incoherent, and replete with run-on sentences, but I wanted to get something down on paper before I headed to bed. Here is the next question that the CPSC is taking comments on regarding component testing.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
Wednesday, December 24, 2008
CPSIA Question 2
Question 2: The conditions and or circumstances, if any, that should be considered in allowing third-party testing of component parts.
The conditions that should be considered in allowing component testing are if the actual components used in the finished product are the same as those that were tested. Provided that each component has not been chemically altered, or any additional raw materials are introduced into the finished product, then component testing should be allowed.
In fact, component testing would be superior to unit testing when one small component would be over the legal limit for lead. For example, the allowable limit is 600 parts per million for the entire unit. If the buttons used on a garment were over that limit, but there were only 2 used on a finished garment, that allowable limit would probably not be exceeded for the unit, but would be exceeded for the component. In this case, component testing would reduce the danger of a small component of the overall product being over the allowable limit for lead.
The conditions that should be considered in allowing component testing are if the actual components used in the finished product are the same as those that were tested. Provided that each component has not been chemically altered, or any additional raw materials are introduced into the finished product, then component testing should be allowed.
In fact, component testing would be superior to unit testing when one small component would be over the legal limit for lead. For example, the allowable limit is 600 parts per million for the entire unit. If the buttons used on a garment were over that limit, but there were only 2 used on a finished garment, that allowable limit would probably not be exceeded for the unit, but would be exceeded for the component. In this case, component testing would reduce the danger of a small component of the overall product being over the allowable limit for lead.
CPSIA Question 1
The CPSC has requested comments from interested parties regarding component vs. unit testing and supplier provided certification. I'm going to take these question by question, even though many seem to be redundant. Please feel free to use my responses as part of your own, but I do think the more varied the verbiage the better. If they hear from many of us in our own voices, maybe they will actually listen.
On to the questions:
Number 1: How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts versus of a finished consumer unit.
The only risk that would be introduced into consumer goods by component testing versus unit testing would be if a manufacturer substituted a different component after the component testing was completed. Say for example a certain trim was used in the prototype and the testing was completed on that particular trim. That trim then became unavailable for production and a different trim was substituted for the production run that was similar, but untested.
Similarly, if the manufacturer embellishes the product with appliqués, roller paints, iron decals, or other such embellishments, and did not have these components tested previously, there might be a chance of introducing non-compliant components.
However, a manufacturer should be allowed to permit the certifications from suppliers for the unaltered component parts, and additionally test those components for which no testing has been performed. Then that unit should be deemed sufficiently tested. Provided the manufacturer tested each component that was part of the finished unit, and no substitutions were made, then no subsequent risk would be introduced.
On to the questions:
Number 1: How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts versus of a finished consumer unit.
The only risk that would be introduced into consumer goods by component testing versus unit testing would be if a manufacturer substituted a different component after the component testing was completed. Say for example a certain trim was used in the prototype and the testing was completed on that particular trim. That trim then became unavailable for production and a different trim was substituted for the production run that was similar, but untested.
Similarly, if the manufacturer embellishes the product with appliqués, roller paints, iron decals, or other such embellishments, and did not have these components tested previously, there might be a chance of introducing non-compliant components.
However, a manufacturer should be allowed to permit the certifications from suppliers for the unaltered component parts, and additionally test those components for which no testing has been performed. Then that unit should be deemed sufficiently tested. Provided the manufacturer tested each component that was part of the finished unit, and no substitutions were made, then no subsequent risk would be introduced.
Saturday, December 20, 2008
waiting for Santa
Here are the velvet knickerbockers. Oh my goodness, my child is looking so "little girl!" Oh the pangs...
strawberry knickerbockers
I love dresses, cute ruffles, twirl skirts, and all the rest. But what I end up dressing my daughter in is usually a little more everyday. These knickerbockers were inspired by a browse through one of my Ottobre Design magazines.
So, I started with a cute little strawberry print corduroy, and decided to make them reversible. Now this seems simple enough, but when I added the cuff on the bottom, it became a little more complicated. Not to mention the fact that I was trying this out at about 11:00pm, when i should have been going to sleep. My first attempt at the reversible part ended up not working. For anyone who knows anything about mobius strips, this will make sense to you. So, you have to leave a small opening and grasp the two raw edges together, and just keep pinning until you have all the appropriate edges together so that when you turn it right side out, it lays together.
On the reverse, I used a gorgeous print from Anna Maria Horner from the garden party line. Lovely. I also love that you get two totally different looks in one. Versatile, cute, and sort of boyish which I think looks adorable on little girls.
Incidentally, I made a pair of these out of a gray and purple velvet I had in my stash, a peasant blouse out of rayon, and a violet linen vest with a ribbon laced grommet detail in the back for her visit to Santa. Alas, my child will probably never sit in his lap, but I did get a couple pictures anyway. I love how the soft velvet looks in this unexpected style, and I hope to offer this in my etsy shop soon.
This picture was taken on our local covered bridge. Can't wait to do a few more there, I love the struts in the background.
CPSIA and NAM
As I was reading Kathleen Fasanella's blog today (it's all good by the way, and there is so much information, it is mind blowing for a designer) there was a link to a petition as set forth by the National Association of Manufacturers (NAM) that I believe is truly outstanding in a "so rational it's scary" sort of way. In it they have petitioned the CPSC to clarify the intent of the CPSC in regards to supplier provided certifications, exemptions for components that have little or no lead in them, and other provisions for inaccessible parts.
It is the best thing I have seen to date, and makes the most sense to me as a small business owner who wants to eventually grow her business. I don't want an exemption from the law just because I am a small manufacturer making things out of my home. I realize that I am a manufacturer, regardless of the size of my company. I want to play by the rules. I want my products to be as safe as they can be. But certain things about complying with this law do not make sense.
Why do we all need to go through the expense of the third party testing when it has already been done by the fabric manufacturer? The thread manufacturer? And the fact remains, that fabrics alone are not a real source of lead to begin with. Perhaps if I were surface coating them, or printing them, I might think twice, but I am not. Forgive me, but we'd all be very, very sick by now if there was a real risk of lead contamination from cotton clothing.
OK here is the petition. It's beautifully written in legalese, so it ought to get someone's attention over there at the CPSC since they are so fond of that language.
Thanks for your support.
Melissa
It is the best thing I have seen to date, and makes the most sense to me as a small business owner who wants to eventually grow her business. I don't want an exemption from the law just because I am a small manufacturer making things out of my home. I realize that I am a manufacturer, regardless of the size of my company. I want to play by the rules. I want my products to be as safe as they can be. But certain things about complying with this law do not make sense.
Why do we all need to go through the expense of the third party testing when it has already been done by the fabric manufacturer? The thread manufacturer? And the fact remains, that fabrics alone are not a real source of lead to begin with. Perhaps if I were surface coating them, or printing them, I might think twice, but I am not. Forgive me, but we'd all be very, very sick by now if there was a real risk of lead contamination from cotton clothing.
OK here is the petition. It's beautifully written in legalese, so it ought to get someone's attention over there at the CPSC since they are so fond of that language.
Thanks for your support.
Melissa
Tuesday, December 16, 2008
CPSIA, It's starting to happen!
OK everyone, all our letters and emails and overall hard work is starting to get the CPSC's attention. They have now opened up comments on component testing. This is important to many of us because if they allow manufacturer's to test each component, and possibly use our supplier's testing results, the costs of conforming will decrease significantly.
I want to ensure my products are safe. To that end I have contacted Westminster Fibers, the fabric company I use for the bulk of my line. Guess what? No detectable lead. Big surprise, right? I also contacted Mettler thread, and because they test using Oeko-tex standards, a very rigorous European program, they are lead free as well.
If I am allowed to use their tests as part of my "reasonable testing program", my costs are significantly decreased. It could be that only my trims and buttons need to be tested, in which case my costs to test could be spread out over a larger product line. And, I wouldn't have to sew up every product before the test could be performed. Batching this out to a lab becomes much simpler and cheaper. This is very, very important, and could mean the survival of my little business.
So here is the link: http://www.cpsc.gov/about/cpsia/cpsia.html and you can scroll down to see just under "What's New" to see the pdf form. These are the questions they are specifically targeting to the industry. It is complicated, but I will post my letter here when I get everything written. The deadline to post your comments is January 30th. The more people we get to respond to this, the better.
I want to ensure my products are safe. To that end I have contacted Westminster Fibers, the fabric company I use for the bulk of my line. Guess what? No detectable lead. Big surprise, right? I also contacted Mettler thread, and because they test using Oeko-tex standards, a very rigorous European program, they are lead free as well.
If I am allowed to use their tests as part of my "reasonable testing program", my costs are significantly decreased. It could be that only my trims and buttons need to be tested, in which case my costs to test could be spread out over a larger product line. And, I wouldn't have to sew up every product before the test could be performed. Batching this out to a lab becomes much simpler and cheaper. This is very, very important, and could mean the survival of my little business.
So here is the link: http://www.cpsc.gov/about/cpsia/cpsia.html and you can scroll down to see just under "What's New" to see the pdf form. These are the questions they are specifically targeting to the industry. It is complicated, but I will post my letter here when I get everything written. The deadline to post your comments is January 30th. The more people we get to respond to this, the better.
Saturday, December 13, 2008
CPSIA, A Form Letter?? Seriously?
Oh yes, seriously. I wrote to my Representative in Congress, Mr. Paul Hodes about the new law that has already gone into effect, and will basically shut my handmade dress business down unless amended. What did I get in return? Some junior staffer sending me a form letter. Whoever it was no doubt saw the initials CPSC, and pulled up the closest thing to it among their computer files for autoresponses. Here is the disgraceful letter I received...
December 11, 2008
Dear Ms. McKeagney,
Thank you for contacting me about consumer product safety. I truly appreciate hearing from you, and I am working hard to stand up for New Hampshire 's interests in Congress.
I share your concerns about the recent safety issues and recalls. I want to make sure that everything possible is being done to protect children in the Granite State and across the country from unsafe toys. Twenty million imported toys manufactured in China and elsewhere were recalled this summer. According to Mattel CEO Bob Eckert, some of these toys contained nearly 200 times the legal limit for lead. Currently, at the Consumer Protection Safety Commission (CPSC), there is only one inspector charged with testing toys to make sure they are safe for our children. Toys are now being sold in our stores that are untested and are unsafe. Even more troubling, the chairwoman of the CPSC, Nancy Nord, said recently that she was opposed to increasing the agency's funding or authority. This is unacceptable, especially when it involves protecting our children.
The CPSC is critical to protecting the safety of all Americans by reducing the unreasonable risk of injury associated with consumer products. The CPSC is responsible for developing uniform safety standards for consumer products, minimizing conflicting state and local regulations, and promoting research into prevention of product-related deaths, illnesses, and injuries. We must adequately fund the CPSC to ensure that only the safest products end up in our stores and in our homes.
I am a proud cosponsor of H.R. 4040, the Consumer Product Safety Modernization Act. This legislation would establish consumer product safety standards and other safety requirements for children's products. H.R. 4040 would also reauthorize and modernize the Consumer Product Safety Commission.
On December 19, 2007, I voted for H.R. 4040, which passed the House by a vote of 407 to 0. On August 14, 2008, H.R. 4040 was signed into law.
Thank you again for sharing your thoughts with me. If you would like more information on this or any other issue, please visit my website at http://hodes.house.gov. Please do not hesitate to contact me in the future to express your views or if I can be of help on any matter.
Sincerely,
Paul Hodes
Member of Congress
And here is the letter I shot back in return. He completely missed my point, because he clearly never read my initial letter.
Congressmen Hodes:
While I appreciate the need to keep our children safe, this law has far reaching unintended consequences. I would appreciate a direct response, and not a form letter to this matter as you did not address a single concern of mine.
I am the owner/manufacturer of little girl Pearl, a girls clothing company, and make everything myself out of my home. I started my business over a year and a half ago, when I took a huge pay cut at my job with the airlines. My little company helps us pay the bills, and makes us feel a little more comfortable at the end of the month. Many of my items are one of a kind, which makes third party testing unfeasible, not to mention the fact that my items are inherently lead free in the first place. I do not use any kind of paint or surface coating, and use mainly quality cotton fabrics for the bulk of my line.
Unfortunately, at this time, component testing is not allowed. Say for example I use 10 different fabrics (for me it's in the hundreds), and 15 different kinds of buttons, and 2 different zippers, and 1 kind of snap. I couldn't just take one of each and have each tested on its own. No, I would have to take hours of my time, sew each product as I do now, and submit it for testing. Well folks, there goes half my inventory right there, not to mention my time. The testing is destructive, so I wouldn't even get the original dress back. It just isn't feasible for us as micro-producers to do the testing in this way, or any manufacturer for that matter. The way the law is written it isn't possible to spread the cost of the testing out among several different styles because you have to test by unit, or each style.
In addition, while the government has ruled that phthalate content testing will not be retroactive from February 10th, 2009, lead testing will be. That means that my current stock becomes illegal to sell past February 10th, unless I submit my dresses to the necessary tests. Regarding the testing, it will cost anywhere between $100-200 at the current rate, and these rates are likely to go up as more manufacturers realize that they must get these tests performed by the deadline. There are only 14 labs that are certified in the U.S. to do this kind of testing. Maybe you know folks who can afford a $200 jumper, but I know I don't. Especially in the current economic state of our country.
It has taken me so much blood, sweat, and tears to build up my company, and the thought of not being able to do what I love is simply heartbreaking. Of course the impetus for the new regulations stemmed from the fiasco of the imported toys from China last year and all of the ensuing recalls. Of course I want to protect our children from unsafe products, but unfortunately this law has gone way too far in its scope. The handmade movement was one of the results from parents wanting to purchase items produced in the U.S. by people who could be their neighbors and friends. Now our government has seen fit to take one more choice away from U.S. consumers and forced them back to products manufactured abroad, and large manufacturers who will have an easier time spreading the costs of testing over a larger product line.
But even the large manufacturers are not without their dilemmas. In a letter dated November 14th, 2008 to Ms. Cheryl Falvey, General Counsel to the CPSC, Mr. Richard Woldenberg, chairman of an educational toy company, stated that Walmart had informed its suppliers of children's products that it intends to return all merchandise regardless of age, that cannot be proven to comply with the new standards. Two other major retailers are rumored to have taken a similar position. If this is the case, you will absolutely see widespread corporate bankruptcies and even more defaults on loans as manufacturers are unprepared to see unprecedented returns of their inventories.
I realize that it is not politically expedient to say that one is against children's safety regulations. But the fact remains that this is going to hurt the economy at a time when we can ill afford one more major sector meltdown. I urge you to take a look at this law and help us Americans try to change it.
Yours Sincerely,
Melissa McKeagney
http://www.littlegirlpearl.com
And, no surprise not a word back yet. I'll keep plugging away, and it's off to the media outlets for me.
December 11, 2008
Dear Ms. McKeagney,
Thank you for contacting me about consumer product safety. I truly appreciate hearing from you, and I am working hard to stand up for New Hampshire 's interests in Congress.
I share your concerns about the recent safety issues and recalls. I want to make sure that everything possible is being done to protect children in the Granite State and across the country from unsafe toys. Twenty million imported toys manufactured in China and elsewhere were recalled this summer. According to Mattel CEO Bob Eckert, some of these toys contained nearly 200 times the legal limit for lead. Currently, at the Consumer Protection Safety Commission (CPSC), there is only one inspector charged with testing toys to make sure they are safe for our children. Toys are now being sold in our stores that are untested and are unsafe. Even more troubling, the chairwoman of the CPSC, Nancy Nord, said recently that she was opposed to increasing the agency's funding or authority. This is unacceptable, especially when it involves protecting our children.
The CPSC is critical to protecting the safety of all Americans by reducing the unreasonable risk of injury associated with consumer products. The CPSC is responsible for developing uniform safety standards for consumer products, minimizing conflicting state and local regulations, and promoting research into prevention of product-related deaths, illnesses, and injuries. We must adequately fund the CPSC to ensure that only the safest products end up in our stores and in our homes.
I am a proud cosponsor of H.R. 4040, the Consumer Product Safety Modernization Act. This legislation would establish consumer product safety standards and other safety requirements for children's products. H.R. 4040 would also reauthorize and modernize the Consumer Product Safety Commission.
On December 19, 2007, I voted for H.R. 4040, which passed the House by a vote of 407 to 0. On August 14, 2008, H.R. 4040 was signed into law.
Thank you again for sharing your thoughts with me. If you would like more information on this or any other issue, please visit my website at http://hodes.house.gov. Please do not hesitate to contact me in the future to express your views or if I can be of help on any matter.
Sincerely,
Paul Hodes
Member of Congress
And here is the letter I shot back in return. He completely missed my point, because he clearly never read my initial letter.
Congressmen Hodes:
While I appreciate the need to keep our children safe, this law has far reaching unintended consequences. I would appreciate a direct response, and not a form letter to this matter as you did not address a single concern of mine.
I am the owner/manufacturer of little girl Pearl, a girls clothing company, and make everything myself out of my home. I started my business over a year and a half ago, when I took a huge pay cut at my job with the airlines. My little company helps us pay the bills, and makes us feel a little more comfortable at the end of the month. Many of my items are one of a kind, which makes third party testing unfeasible, not to mention the fact that my items are inherently lead free in the first place. I do not use any kind of paint or surface coating, and use mainly quality cotton fabrics for the bulk of my line.
Unfortunately, at this time, component testing is not allowed. Say for example I use 10 different fabrics (for me it's in the hundreds), and 15 different kinds of buttons, and 2 different zippers, and 1 kind of snap. I couldn't just take one of each and have each tested on its own. No, I would have to take hours of my time, sew each product as I do now, and submit it for testing. Well folks, there goes half my inventory right there, not to mention my time. The testing is destructive, so I wouldn't even get the original dress back. It just isn't feasible for us as micro-producers to do the testing in this way, or any manufacturer for that matter. The way the law is written it isn't possible to spread the cost of the testing out among several different styles because you have to test by unit, or each style.
In addition, while the government has ruled that phthalate content testing will not be retroactive from February 10th, 2009, lead testing will be. That means that my current stock becomes illegal to sell past February 10th, unless I submit my dresses to the necessary tests. Regarding the testing, it will cost anywhere between $100-200 at the current rate, and these rates are likely to go up as more manufacturers realize that they must get these tests performed by the deadline. There are only 14 labs that are certified in the U.S. to do this kind of testing. Maybe you know folks who can afford a $200 jumper, but I know I don't. Especially in the current economic state of our country.
It has taken me so much blood, sweat, and tears to build up my company, and the thought of not being able to do what I love is simply heartbreaking. Of course the impetus for the new regulations stemmed from the fiasco of the imported toys from China last year and all of the ensuing recalls. Of course I want to protect our children from unsafe products, but unfortunately this law has gone way too far in its scope. The handmade movement was one of the results from parents wanting to purchase items produced in the U.S. by people who could be their neighbors and friends. Now our government has seen fit to take one more choice away from U.S. consumers and forced them back to products manufactured abroad, and large manufacturers who will have an easier time spreading the costs of testing over a larger product line.
But even the large manufacturers are not without their dilemmas. In a letter dated November 14th, 2008 to Ms. Cheryl Falvey, General Counsel to the CPSC, Mr. Richard Woldenberg, chairman of an educational toy company, stated that Walmart had informed its suppliers of children's products that it intends to return all merchandise regardless of age, that cannot be proven to comply with the new standards. Two other major retailers are rumored to have taken a similar position. If this is the case, you will absolutely see widespread corporate bankruptcies and even more defaults on loans as manufacturers are unprepared to see unprecedented returns of their inventories.
I realize that it is not politically expedient to say that one is against children's safety regulations. But the fact remains that this is going to hurt the economy at a time when we can ill afford one more major sector meltdown. I urge you to take a look at this law and help us Americans try to change it.
Yours Sincerely,
Melissa McKeagney
http://www.littlegirlpearl.com
And, no surprise not a word back yet. I'll keep plugging away, and it's off to the media outlets for me.
My Studio
As promised to someone, although I can't remember who at this point, about as much of my studio as I am willing to reveal. These rolling units were purchased from our local middle school as they were preparing to move to new digs near the high school. We got them for a song, but more than a little bit of elbow grease to get them into the truck bed and then into our house. They weigh a ton! But, they are amazing. They are about 3 feet deep, so I can put a ton of fabric in each one, and coordinate by color. Such an improvement for me, as nothing gets lost in the shuffle. I can see exactly what I have, and what I might need to order more of, although with my propensity to over-order, this hasn't been an issue.
I put all of the pre-washed fabrics in the cubbies, and leave the bolts on top and wash as needed. I store all of my ribbons and trims in a high boy around the corner. This has been a god-send as everything used to be all jumbled up in a box. My buttons are all organized in an old block printing drawer (you know the letter stamps they used to use to print newspapers) and each is divided by style. The whole drawer sits on top of the high boy, and I can see each button at a glance. I am by nature a disorganized person, but I found that I was wasting more time looking for things than I was sewing! Being organized in my workspace has made me a whole lot more efficient. Now if I could just tackle my sewing table!
I promise more pictures once that happens, but right now it isn't fit for publication!
Friday, December 12, 2008
Olive and Pumpkin fabrics
Here is another inspired choice. I love using colors that are ignored in the world of girl. Pink is great. Pink is lovely. But I get tired of it! These unusual colors will stand out in a sea of pink, and is great for those darker winter days.
New Skirts!
I love thinking about texture, color, pattern. In fact, I really never stop thinking about it. My daughter loves her twirly skirts, but cotton just seems a little too insubstantial for our winters. So, I headed to the Dorr Mill Store which stocks the most fabulous 100% wools imaginable. They have every color of the rainbow, hand-dyes, british woolens, and pendleton wools. Gorgeous. I limited myself to two new colors, and can't wait to have the time to sew them up into my new drop waist style. And I can't resist a bit of vintage trim and ribbon. Should be fun!
Thursday, December 11, 2008
A Few New Links for CPSIA Activism
I ran across these today, and I thought they were very worthwhile. So here you go...
http://www.thesmartmama.com/bg/index.php?option=com_content&task=view&id=195&Itemid=23
http://www.cpsia-central.ning.com
Also, search CPSC or CPSIA in the etsy forums, and there are some good links too. Be careful of misinformation though, people are grasping at straws to try to find loopholes in the law. At this time, there are none. Please do everything you can to get this law amended.
Write directly to Barack Obama and Joe Biden at:
http://change.gov/page/s/economy
http://www.thesmartmama.com/bg/index.php?option=com_content&task=view&id=195&Itemid=23
http://www.cpsia-central.ning.com
Also, search CPSC or CPSIA in the etsy forums, and there are some good links too. Be careful of misinformation though, people are grasping at straws to try to find loopholes in the law. At this time, there are none. Please do everything you can to get this law amended.
Write directly to Barack Obama and Joe Biden at:
http://change.gov/page/s/economy
Wednesday, December 10, 2008
The CPSIA and its Unintended Consequences
I have been putting off writing this because it just makes me feel heartsick. I have felt a bit like chicken little whenever I have talked about this new law to my friends because when I bring up the consequences of this new law under the Consumer Protection Safety Commission, it feels like I'm saying the sky is falling. But for many of us with handcrafted products and small businesses, this really is the case.
To recap the law as I understand it, all products that are intended for the use of children under the age of 12 must now be sold with a Certificate of General Conformity. That certificate must state that the product in question has been certified for minimum parts per billion of lead and if applicable phthalate content. This includes fabrics, buttons, zippers, surface coated materials, toys, books, electronics, and the like. Basically nothing is exempt whether you make one of a kind items, or are the importer/manufacturer of articles that wind up in big box stores. It effects everyone. The manufacturers of the raw materials are not subject to this testing, because these items are not largely marketed to children themselves. It is up to the manufacturer of the item to perform the necessary testing.
Unfortunately, at this time, component testing is not allowed. Say for example I use 10 different fabrics (for me it's in the hundreds), and 15 different kinds of buttons, and 2 different zippers, and 1 kind of snap. I couldn't just take one of each and have each tested on its own. No, I would have to take hours of my time, sew each product as I do now, and submit it for testing. Well folks, there goes half my inventory right there, not to mention my time. The testing is destructive, so I wouldn't even get the original dress back. It just isn't feasible for us as micro-producers to do the testing in this way, or any manufacturer for that matter. The way the law is written it isn't possible to spread the cost of the testing out among several different styles because you have to test by unit, or each style.
In addition, while the government has ruled that phthalate content testing will not be retroactive from February 10th, 2009, lead testing will be. That means that my current stock becomes illegal to sell past February 10th, unless I submit my dresses to the necessary tests. Regarding the testing, it will cost anywhere between $100-200 at the current rate, and these rates are likely to go up as more manufacturers realize that they must get these tests performed by the deadline. There are only 14 labs that are certified in the U.S. to do this kind of testing. Do you know anyone who can afford a $200 jumper? I know I don't. Especially in the current economic state of our country.
It has taken me years to build up my wonderful fabric stash, and the thought of not being able to do what I love is simply heartbreaking. Of course the impetus for the new regulations stemmed from the fiasco of the imported toys from China last year and all of the ensuing recalls. Of course I want to protect our children from unsafe products, but unfortunately this law has gone way too far in its scope. The handmade movement was one of the results from parents wanting to purchase items produced in the U.S. by people who could be their neighbors and friends. Now our government has seen fit to take one more choice away from U.S. consumers and forced them back to products manufactured abroad, and large manufacturers who will have an easier time spreading the costs of testing over a larger product line.
But even the large manufacturers are not without their dilemmas. In a letter dated November 14th, 2008 to Ms. Cheryl Falvey, General Counsel to the CPSC, Mr. Richard Woldenberg, chairman of an educational toy company, stated that Walmart had informed its suppliers of children's products that it intends to return all merchandise regardless of age, that cannot be proven to comply with the new standards. Two other major retailers are rumored to have taken a similar position. If this is the case, you will absolutely see widespread corporate bankruptcies.
So here is what you can do. I am urging everyone to write to their legislators and call if you can, to tell them that you want this law amended or repealed to protect artisans and craftspeople who are simply trying to pay their mortgages and support their families. Write to tell them that you want a choice in the marketplace, and don't want to buy only mass produced items for your children. While everyone wants safe products, I am urging you to let them know that they are only hurting American families who are trying to do the right thing in the first place. I implore you to let them know that they should not be regulating things like fabric that have very little to no lead in them in the first place.
Here are some helpful links for more information:
http://www.fashion-incubator.com (The forum regarding the CPSIA has been opened to the public)
http://www.nationalbankruptcyday.com
If you want to try to interpet the law yourself here are some of the goverment links :
A copy of the actual law as it stands today: http://www.cpsc.gov/cpsia.pdf
The general CPSIA website : http://www.cpsc.gov/about/cpsia/cpsia.html
Standard Operating Procedure for Determining Total Lead : http://www.cpsc.gov/ABOUT/Cpsia/CPSC-CH-E1001-08.pdf
Original CPSIA FAQs http://www.cpsc.gov/about/cpsia/faq/faq.html#educational
Most recent updates to FAQs : http://www.cpsc.gov/about/cpsia/faq/newfaqs.pdf
How CSPIA effects exsisting inventory & by extension vintage, resale, & recycling of children's items :
http://www.cpsc.gov/library/foia/advisory/317.pdf
Here's links to write your district's congressperson and senate represenatives as long as your still a registered voter. Otherwise write directly to the CPSIA voicing your concern.
https://writerep.house.gov/writerep/welcome.shtml
http://www.senate.gov/general/contact_information/senators_cfm.cfm
http://www.cpsc.gov/cgibin/newleg.aspx
Thanks for doing all you can.
To recap the law as I understand it, all products that are intended for the use of children under the age of 12 must now be sold with a Certificate of General Conformity. That certificate must state that the product in question has been certified for minimum parts per billion of lead and if applicable phthalate content. This includes fabrics, buttons, zippers, surface coated materials, toys, books, electronics, and the like. Basically nothing is exempt whether you make one of a kind items, or are the importer/manufacturer of articles that wind up in big box stores. It effects everyone. The manufacturers of the raw materials are not subject to this testing, because these items are not largely marketed to children themselves. It is up to the manufacturer of the item to perform the necessary testing.
Unfortunately, at this time, component testing is not allowed. Say for example I use 10 different fabrics (for me it's in the hundreds), and 15 different kinds of buttons, and 2 different zippers, and 1 kind of snap. I couldn't just take one of each and have each tested on its own. No, I would have to take hours of my time, sew each product as I do now, and submit it for testing. Well folks, there goes half my inventory right there, not to mention my time. The testing is destructive, so I wouldn't even get the original dress back. It just isn't feasible for us as micro-producers to do the testing in this way, or any manufacturer for that matter. The way the law is written it isn't possible to spread the cost of the testing out among several different styles because you have to test by unit, or each style.
In addition, while the government has ruled that phthalate content testing will not be retroactive from February 10th, 2009, lead testing will be. That means that my current stock becomes illegal to sell past February 10th, unless I submit my dresses to the necessary tests. Regarding the testing, it will cost anywhere between $100-200 at the current rate, and these rates are likely to go up as more manufacturers realize that they must get these tests performed by the deadline. There are only 14 labs that are certified in the U.S. to do this kind of testing. Do you know anyone who can afford a $200 jumper? I know I don't. Especially in the current economic state of our country.
It has taken me years to build up my wonderful fabric stash, and the thought of not being able to do what I love is simply heartbreaking. Of course the impetus for the new regulations stemmed from the fiasco of the imported toys from China last year and all of the ensuing recalls. Of course I want to protect our children from unsafe products, but unfortunately this law has gone way too far in its scope. The handmade movement was one of the results from parents wanting to purchase items produced in the U.S. by people who could be their neighbors and friends. Now our government has seen fit to take one more choice away from U.S. consumers and forced them back to products manufactured abroad, and large manufacturers who will have an easier time spreading the costs of testing over a larger product line.
But even the large manufacturers are not without their dilemmas. In a letter dated November 14th, 2008 to Ms. Cheryl Falvey, General Counsel to the CPSC, Mr. Richard Woldenberg, chairman of an educational toy company, stated that Walmart had informed its suppliers of children's products that it intends to return all merchandise regardless of age, that cannot be proven to comply with the new standards. Two other major retailers are rumored to have taken a similar position. If this is the case, you will absolutely see widespread corporate bankruptcies.
So here is what you can do. I am urging everyone to write to their legislators and call if you can, to tell them that you want this law amended or repealed to protect artisans and craftspeople who are simply trying to pay their mortgages and support their families. Write to tell them that you want a choice in the marketplace, and don't want to buy only mass produced items for your children. While everyone wants safe products, I am urging you to let them know that they are only hurting American families who are trying to do the right thing in the first place. I implore you to let them know that they should not be regulating things like fabric that have very little to no lead in them in the first place.
Here are some helpful links for more information:
http://www.fashion-incubator.com (The forum regarding the CPSIA has been opened to the public)
http://www.nationalbankruptcyday.com
If you want to try to interpet the law yourself here are some of the goverment links :
A copy of the actual law as it stands today: http://www.cpsc.gov/cpsia.pdf
The general CPSIA website : http://www.cpsc.gov/about/cpsia/cpsia.html
Standard Operating Procedure for Determining Total Lead : http://www.cpsc.gov/ABOUT/Cpsia/CPSC-CH-E1001-08.pdf
Original CPSIA FAQs http://www.cpsc.gov/about/cpsia/faq/faq.html#educational
Most recent updates to FAQs : http://www.cpsc.gov/about/cpsia/faq/newfaqs.pdf
How CSPIA effects exsisting inventory & by extension vintage, resale, & recycling of children's items :
http://www.cpsc.gov/library/foia/advisory/317.pdf
Here's links to write your district's congressperson and senate represenatives as long as your still a registered voter. Otherwise write directly to the CPSIA voicing your concern.
https://writerep.house.gov/writerep/welcome.shtml
http://www.senate.gov/general/contact_information/senators_cfm.cfm
http://www.cpsc.gov/cgibin/newleg.aspx
Thanks for doing all you can.
Sunday, December 7, 2008
How to Have a Good Slow Craft Show
No, the two are not mutually exclusive. Yesterday's show in Canterbury wasn't as busy as we all would have liked. But everyone knows that folks are pulling back a little this year. So, what can we as vendors do? Here's my top 5:
1. Get excited about your craft. Even if the buyers weren't buying, they were talking. I got so much positive feedback on my designs that it was a real thrill. If you feel positive about your work, it shows. Don't let the lack of a monetary reward get you down. And hopefully you gave out enough business cards that people will think of you when they do have that extra disposable income to spend.
2. Stay positive. Please don't be that vendor (whom we have all seen) that sits with their arms crossed behind their table or display and never comes out front to see what is going on. Chat up the customers who are there. And I don't mean push your wares. But be polite, make conversation, and look interested. When someone is buying something that you made, they want to feel like their hard earned dollar is going to someone who appreciates what it took to earn it.
3. Talk to the other vendors. I learned a great little nugget of information from both the vendors near to me, and bartered with one for the most gorgeously made paper earrings. She got some ponytail holders for her daughter for Christmas, and I received a piece of her art. What could be better!
4. Remember that these shows are always hit and miss. Learn from everything. What do your customers pick up? What do they buy? And more importantly what never sees the light of day? How could you market that item better? Make it a learning experience from start to finish. Every time I do a show I try to figure out how I can make my booth/table more attractive and convenient for shoppers.
5. Use the down time to create if possible. I was able to bead a few of my hair florettes during the slow time, making me feel productive at the very least. If you are able to do so, bring some supplies along so that you can create, and maybe even engage a few shoppers in the process.
Every show for me is new and exciting. I realize that a lot of vendors have been doing shows for eons and are way more experienced than I, but sometimes a fresh pair of eyes helps to refocus, and put things in perspective. I don't know when my next show will be, but I already have some ideas to experiment with, and am grateful I'm able to do what I love!
Friday, December 5, 2008
scary bat costume
You know, they say the most unexpected things! In preparation for our daughter's first "real" halloween, (we went last year, but in a borrowed costume, so it doesn't really count), I asked her about 4 weeks beforehand what she would like to be. I wasn't even really sure she knew what halloween was, let alone what she'd like to dress up as.
So, I asked her on three separate occasions about her costume, and her answer each time was the same, "a scary bat". What?? Really? Not, cinderella or ariel? Her obsession with these movies is huge, you see. Nope, nothing doin'. A scary bat.
Not one to buy costumes anyway, I thought for sure this would be a whole lot easier than a disney princess. So, off to the fabric store. Black fabric, a novelty fabric on the outside with spider webs and purple sparkles ("it's so beautiful" she says as I'm cutting it out). Boning to make the points stand out, and voila, a scary bat costume.
She was so proud! And yes, all her friends were princesses, so I was proud too. The only thing I would've changed is to put some reflective material somewhere, because you could barely see her running on the sidewalk. She got (and ate!) piles of candy, and we had tons of fun. I wonder what she'll dream up next year...
Tuesday, December 2, 2008
Down to Business
Couple of things going on for me, that are keeping me busy. First is the etsykids team trunk show that will take place in the etsy virtual labs (http://www.etsy.com/virtual_labs.php) on Thursday, December 4th, at 8pm EST. I will be doing a presentation along with others from the team about our shops and creative process. There are lots of special offers and free giveaways, so it should be lots of fun. Mark your calendars!
The other bit of business is that I will be doing a show in Canterbury NH at the elementary school on Saturday, December 6th. So, for those of you who are local, please come out and support handmade!
The other bit of business is that I will be doing a show in Canterbury NH at the elementary school on Saturday, December 6th. So, for those of you who are local, please come out and support handmade!
hippie chick outfit
A new style for me, and a top I had been putting off making. Generally I don't love wrap style blouses because I always wonder whether they will stay put when worn. Wonder no more, this little blouse is sturdy! It ties on both sides, with ties made from bias. The whole blouse is lined, including the sleeves, and I am digging the polka dot ruffle.
All fabrics are from Anna Maria Horner's garden party line. Totally beautiful, I cannot get enough of all the colors. Green is a fave of mine anyway, and I can't wait to do more of these little tops, maybe in blue. I think a long sleeve modification would look amazing too, so that might be next on my creative docket.
So the name you say? My husband, whose first impression declarations are often the names of my creations, decided this one was oh so "grateful dead". Huh? Really? I don't know, he's a huge fan, but I did decide to call it the hippie chick.
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